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Home My WebLink About08-5863IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. RICHARD M MOONEY Defendant No. COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06432968 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. RICHARD M MOONEY Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at 2171 NW 139 TERR, PEMBROKE PINES, FL 33028. 2. Defendant is an adult individual residing at 510 FIRST ST, CARLISLE, PA 17013. COUNT I - ACCT NO. 9304506 At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER provided certain medical services to Defendant. 4. This obligation was subsequently assigned to Plaintiff for value. 5. Defendant, RICHARD M MOONEY, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 6. The prices charged by Plaintiff's assignor were the prices that Defendant, RICHARD M MOONEY, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, RICHARD M MOONEY, in the amount of $1377.06 as of SEPTEMBER 19, 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from SEPTEMBER 19, 2008. 9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the aforementioned balance, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, RICHARD M MOONEY, in the amount of $1377.06 as to Count I, with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 19, 2008 and costs. COUNT II: ACCOUNT NO -9344417 10. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER provided certain medical services to Defendant. 11. This obligation was subsequently assigned to Plaintiff for value. 12. Defendant, RICHARD M MOONEY, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 13. The prices charged by Plaintiff's assignor were the prices that Defendant, RICHARD M MOONEY, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, RICHARD M MOONEY, in the amount of $100.00 as of SEPTEMBER 19, 2008. 15. Plaintiff claims interest at the legal rate of six (6%) percent per annum from SEPTEMBER 19, 2008. 16. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the aforementioned balance, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, RICHARD M MOONEY, in the amount of $100.00 as to Count II, totaling $1477.06 for Counts I & II with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 19. 2008 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. l1/? WILLIAM T. MOLCZA/ Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR4:06432968 0611310T PAGE 001 HEALTH MANAGEMt4T ASSOCIATES UAI/ COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: MOONEY, RICHARD M F/C: B P/T: I A/C: 9304506 DSC CODE: 01 TO: MOONEY, RICHARD M ADMISSION: 02/22/05 DISCHARGE: 02/26/05 510 FIRST ST CARLISLE PA 17013 INS CD: 200/BC5 BLUE CROSS 361 COMP GROUP 005060140000 POL ID: YWC200361 D E P A R T M E N T A M O U N T 2,600.00 3,566.01 2,016.23 1,912.38 292.65 2,018.29 390.66 1,868.98 2,326.19 3,839.'94- 13,151.45- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT r 06/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: MOONEY, RICHARD M F/C: B P/T: E A/C: 9344417 DSC CODE: 01 TO: MOONEY, RICHARD M ADMISSION: 07/16/06 DISCHARGE: 07/16/06 510 FIRST ST CARLISLE PA 17013 INS CD: 200/BC5 BLUE CROSS 303 COMP GROUP 295860DV1 POL ID: DPV877881 D E P A R T M E N T A M O U N T 24.32 107.60 1,553.06 851.53- 833.45- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn falsifications to authorities, that she is GAIL WOOD (Name) DIRECTOR of Customer Care of INTERNATIONAL PORTFOLIO INC., plaintiff (Title) (Company) herein, that she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of her knowledge, information and belief. (Signature) WWR# ca -n V( ? I ?F ` ! \ t r SHERIFF'S RETURN - REGULAR CASE NO: 2008-05863 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS MOONEY RICHARD M ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MOONEY RICHARD M DEFENDANT was served upon the , at 0013:34 HOURS, on the 8th day of October , 2008 at 510 FIRST STREET CARLISLE, PA 17013 RICHARD MOONEY DEFENDANT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 5.00 Affidavit 00 Surcharge 10.00 R. Thomas Kline • 00 / fl /^ 33.00 10/09/2008 WELTMAN WEINBERG & REIS Sworn and Subscibed to By 4a? before me this day Deputy Sheriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. RICHARD M MOONEY Defendants No. 08-5863 CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, P.A.I.D.# 42524 Weltman,Weinberg & Reis Co.,L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412)134-7955 Fax: 412-338-7130 WWR#6432968 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-5863 CIVIL RICHARD M MOONEY Defendants PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREDJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue the above captioned matter upon the records of the Court with prejudice and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W odt, P.A.I.D.# 4 24 Weltman, ein erg & Reis Co.,L.P.A. 436 Seve h venue, Suite 1400 Pittsburg . P 15219 (412)43f-7955 Fax: 41 38-7130 WWR#6432968 Sworn to and subscribed Before me the ay of APRIL, 2009 Y PUB COMMONWEALTH OF PENNSYLVANIA L Nota!W Heidt r Kell, WCtW PUbllc Oty Of Pfl .Wi, AI%I'K Y C unty My t;dr nwah E*M Nov. 4, 2ty08 Member, Pennsylvenle Ass"Otlan c?i Noterlee FiLEI.._' ,kCE P, )TAPY 2003 MAY - i F ! 44 NITY ry i bb `°? ?P{ h k, n.